ML20127D031
| ML20127D031 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/11/1993 |
| From: | Spitzberg B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20127D018 | List: |
| References | |
| 50-285-92-32, NUDOCS 9301150067 | |
| Download: ML20127D031 (4) | |
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APPENDIX 4 NOTICE Of VIOLATION Omaha Public Power District Docket:
50-285 fort Calhoun Station License:
DPR-40 During an NRC inspection conducted December 14-18, 1992, violations of NRC requirements were identified.
These violations involved failures to follow procedures and a failure to use engineering controls.
In accordance with the
" General Statement of Policy and Proccoure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1991), the violations are listed below:
A.
Technical Specification 5.8.1 states, in part, that written procedures and administrative policies shall be established, implemented, and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of Regulatory Guide 1.33.
1.
Regulatory Guide 1.33, Appendix A, Section 7.e(l) states, in part, that access control to radiation areas by a radiation work permit system should be covered by written procedures.-
Radiation Protection Procedure RP-201, Section 7.6.2.A(2), states, in part, that a radiation work permit should be revised when radiological conditions change requiring additional controls.
Contrary to the above, the licensee identified that on April 16, 1992, radiological conditions had changed during the change-out of the letdown purification filters and the contract radiation protection technician did not stop the job and have the radiation work permit revised.
Specifically, the letdown filters were found to be drier than usual, which resulted in an airborne
' radioactivity problem.
This is a Severity Level IV violation (Supplement IV)
(285/9232-01).
2.
Regulatory Guide 1.33, Appendix A, Section 7.e(2) states, in part, that radiation surveys should be covered by written procedures, a.
Radiation Protection Procedure RP-202, Section 7.1.1.B(1)(a), states, in part, that beta radiation dose rates shall initially be measured at contact when internal surfaces of primary or radwaste systems are accessible and worked on.
Contrary to the above, the licensee identified that on April 16, 1992, when the letdown purification filters of the l
Chemical and Volume Contr01 System were changed out, that beta radiation dose rates were not measured.
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,. This is a Severity Level IV violation (Supplement IV)
(285/9232-02).
b.
Radiation Protection Procedure RP-202, Section 7.1.2.C(l),
states, in part, that loose surface contamination samples taken during breach of primary systems are to be counted for gross alpha activity.
Contrary to the abov1, the-licensee identified that the loose surface contamination samples that were taken on April 16, 1992, during the breach of the Chemical and Volume Control System to change the letdown filters, were not counted for gross alpha activity.
This is a Severity Level IV violation (Supplement IV)
(285/9232-03).
c.
Radiation Protection Procedure RP-202, Section 7.5.2 states, in part, that the Radiological Operation Coordinator, or his designee, shall review all surveys.
Section 7.5.4.A, states, in part, that the review shall address the adequacy of survey data with respect to the reason for performing the survey.
Contrary to the above, the licensee identified that reviews of the surveys performed on April 16, 1992,. in support of the letdown filter change-out, did not address the adequacy of the survey data.
Specifically, the reviews did not detect that beta dose rates and alpha counts should have been performed and were not.
This is a Severity Level V violation (Supplement IV)
(285/9232-04).
3.
Regulatory Guide 1.33, Appendix A, Section 7.e(5) states, in part, that respiratory protection should be covered by written procedures.
a.
Radiation Protection Procedure RP-203, Section 7.1.2.A and B, states, in part, that job coverage air samples shall be taken as directed by the Radiation Work Permit at the start of work likely to cause airborne activity, such as disassembly of highly contaminated components and during-work requiring respiratory protection.
Contrary to the above, the licensee identified that on-April 16, 1992, an air sample was not taken at the start of work in Room 11 to support Radiation Work Permit 92-3025 work which required respiratory protection..Specifically, one of the letdown filters had already been changed'out before the air sample in Room 11 was started.
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i i This is a repeat violation.
This is a Severity Level IV violation (Supplement IV)
(285/9207-05).
b.
Radiation Protection Procedure RP-204, Section 7.2.7, states, in part, that the licensee post Airborne Radioactivity Areas where the concentration of airborne radioactive materials exceed 25 percent of 1 MPC.
Contrary to the above, the licensee identified that on April 16,1992, Room 11 where the letdown filters were changed out was not posted as an Airborne Radioactivity Area.
Past job evolutions indicated that the concentration of the airborne radioactive materials in Room 11 exceeded 25 percent of 1 MPC when the filters were changed, and the concentration exceeded 25 percent of 1 MPC on April 16, 1992.
This is a Severity level IV violation (Supplement IV)
(285/9207-06).
B.
10 CFR 20.103(b)(1) requires that the licensee, as a precautionary procedure, use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive materials in air to levels below those which delimit an airborne radioactivity area as defined in 10 CFR 20.203(d)(1)(ii),
10 CfR 20.203(d)(1)(ii) states, in part, that an airborne radioactivity area is any room, enclosure, or operating area in which airborne radioactive material composed wholly or partly of licensed material exists in concentrations which, averaged over the number of hours in any a
week during which individuals are in the area, exceed 25 percent of the amounts specified in Appendix B, Table 1, Column 1 of Part 20.
Contrary to the above, the licensee identified that on April 16, 1992, engineering controls were not used to the extent practicable to limit concentrations of radioactive materials in air to levels below those which delimit an airborne radioactivity area as defined in 10 CFR 20.203(d)(1)(ii).
This is a Severity Level IV violation (Supplement IV) (285/9207-07).
Pursuant to the provisions of 10 CFR 2.20', Craha Public Power District is hereby required to submit a written statement cc explaration to the U.S.
Nuclear Regulatory Commission, ATIN: Document Control Desk, Washington, D.C.
20555 with a copy to the Regional Administratcr, Region IV, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Rcply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the
. corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further vinlations, and (4) the
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date when full compliance will be achieved, if an adequate reply is not rt.
- Jed within the time specified by this Notice, an order may be issued to
< hoe use why the license should not be modified, suspended, or revoked, or nny sc h other action as may be proper should not be taken. Where good cause s shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this 11thday of January 1993 2
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